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Tribunal rightly concluded that original return did not survive and thus, claim for carry forward of speculation loss raised for first time in revised return was to be allowed as assessee having filed original return under section 139(1) and revised the same within period prescribed under section 139(5)

GUJARAT HIGH COURT

 

No.- TAX APPEAL NO. 492 of 2017

 

PRINCIPAL COMMISSIONER OF INCOME TAX.....................................Appellant.
V
BABUBHAI RAMANBHAI PATEL ............................................................Respondent

 

MR.JUSTICE AKIL KURESHI AND HONOURABLE MR.JUSTICE BIREN VAISHNAV

 
Date :July 17, 2017
 
Appearances

MRS MAUNA M BHATT, ADVOCATE FOR THE APPELLANT


Section 139 of the Income Tax Act, 1961 — Return of Income — Tribunal rightly concluded that original return did not survive and thus, claim for carry forward of speculation loss raised for first time in revised return was to be allowed as assessee having filed original return under section 139(1) and revised the same within period prescribed under section 139(5) — Principal Commissioner of Income Tax vs. Babubhai Ramanbhai Patel.


JUDGMENT


MR.JUSTICE AKIL KURESHI J- Tax appeal is admitted for consideration of following substantial question of law :

Whether the Appellate Tribunal was right in treating business income of Rs. 2,31,17,992/- as Short Term Capital Gain and Rs. 11,27,984/- as Long Term Capital Gain and Rs. 11,12,073/- as Long Term Capital Loss?

2. We notice that the revenue has also suggested one more question which reads as under:

Whether the Appellate Tribunal was right in facts and circumstances in deleting the disallowances of interest of Rs. 1,11,22,812/- confirmed by the CIT(A), pertaining to A.Y 2005-06?

3. With respect to this question, we notice that the CIT(A) confirms with the Assessing Officer that interest expenditure of Rs. 1.11 crores had to be disallowed. However, the Tribunal noted that the advances were made by the assessee to one Kanak Castor Products Private Limited. Kanak Castor was declared as the highest bidder for purchase of assets of a company in liquidation by the Gujarat High Court. To facilitate the purchase, the assessee had also purchased 4.79 crores shares out of 5 crores shares of the company i.e. Kanak Castor. The Tribunal, therefore, found that such advances were made for the purpose of business. We do not find any error in the view of the Tribunal. This question is, therefore, not considered.

 

[2017] 249 TAXMAN 470 (GUJ)

 
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